Paradigm Shift Of The Tax Avoidance Concept: A Comparative View,
2015
Texas A&M University School of Law
Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes
William H. Byrnes
No abstract provided.
Capital In The Twenty-First Century. By Thomas Piketty [Book Review],
2015
Boston College Law School
Capital In The Twenty-First Century. By Thomas Piketty [Book Review], Frank Garcia
Frank J. Garcia
No abstract provided.
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty,
2015
Florida International University
The Treasury's Twenty Year Battle With Treaty Shopping: Article 16 Of The 1977 United States Model Treaty, Robert R. Oliva
Georgia Journal of International & Comparative Law
No abstract provided.
Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology,
2015
Liddell, Sapp, Zivley, and Laboon
Mining Investment In Brazil, Peru, And Mexico: A Practical Methodology, Gerald J. Pels
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983.,
2015
University of Georgia School of Law
Book Review: Bibliography On Taxation Of Foreign Operations And Foreigners. Elisabeth A. Owens And Gretchen A. Hovemeyer. Cambridge, Massachusetts: International Tax Program, The Law School Of Harvard University, 1983., John C. O'Byrne
Georgia Journal of International & Comparative Law
No abstract provided.
All Or Nothing? The Obama Budget Proposals And Beps,
2015
University of Michigan Law School
All Or Nothing? The Obama Budget Proposals And Beps, Reuven S. Avi-Yonah
Articles
There is a wide bipartisan consensus that the U.S. international tax regime is broken. We have the highest corporate tax in the OECD, which at 35 percent imposes a real burden on corporations earning mostly U.S.-source income. At the same time, U.S.-based multinationals pay very low effective tax rates on foreign-source income earned through their subsidiaries, leading to a strong incentive to shift profits out of the United States. Finally, the United States is among the few countries to fully tax dividends paid by foreign subsidiaries to their domestic parents, leading to the “trapped income” phenomenon in which $2 trillion …
Disc To Fsc: A Small Business Alternative?,
2015
University of Georgia School of Law
Disc To Fsc: A Small Business Alternative?, Scott J. Klosinski
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed,
2015
University of Georgia School of Law
Tax Reform Act Of 1984 - International Related-Party Factoring - A Major Tax Loophole For Multinational Corporations Is Closed, Phil Conner
Georgia Journal of International & Comparative Law
No abstract provided.
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors,
2015
University of Georgia School of Law
Tax Reform Act Of 1984 - Netherlands Antilles - Effect Of The Repeal Of The Withholding Tax On Portfolio Interest Payments To Foreign Investors, Lee C. Dilworth
Georgia Journal of International & Comparative Law
No abstract provided.
New Tax Withholding Rules For Foreign-Owned United States Real Estate,
2015
Hansell & Post
New Tax Withholding Rules For Foreign-Owned United States Real Estate, John D. Maiers
Georgia Journal of International & Comparative Law
No abstract provided.
A Whole New World: Income Tax Considerations Of The Bitcoin Economy,
2015
Georgia Gwinnett College
A Whole New World: Income Tax Considerations Of The Bitcoin Economy, Benjamin W. Akins Jd, Llm, Jennifer L. Chapman Jd, Cpa, Jason M. Gordon Jd, Mba
Benjamin W. Akins
Bitcoin is a virtual, cryptocurrency growing rapidly in influence throughout the world. Numerous characteristics associated with the bitcoin system, including low transaction costs and greater user privacy, make it appealing as a medium of electronic payment. The number of users of bitcoin, including merchants accepting the currency as a form of payment, has grown considerably in recent years. Estimates indicate that there are more than 60,000 active bitcoin users as of September 2012, with nearly 11 million bitcoins in existence. According to the latest estimates, bitcoin market capitalization is roughly $9 billion. The growth of bitcoin as an accepted currency …
Definitions, Religion, And Free Exercise Guarantees,
2015
Capital University Law School
Definitions, Religion, And Free Exercise Guarantees, Mark Strasser
Mark Strasser
The First Amendment to the United States Constitution protects the free exercise of religion. Non-religious practices do not receive those same protections, which makes the ability to distinguish between religious and non-religious practices important. Regrettably, members of the Court have been unable to agree about how to distinguish the religious from the non-religious—sometimes, the implicit criteria focus on the sincerity of the beliefs, sometimes the strength of the beliefs or the role that they play in an individual’s life, and sometimes the kind of beliefs. In short, the Court has virtually guaranteed an incoherent jurisprudence by sending contradictory signals with …
Arbitration - Arbitrability Of Antitrust Claims Arising From An International Commercial Contract - Mitsubishi Motors Corp. V. Soler Chrysler-Plymouth, Inc., 105 S. Ct. 3346 (1985).,
2015
University of Georgia School of Law
Arbitration - Arbitrability Of Antitrust Claims Arising From An International Commercial Contract - Mitsubishi Motors Corp. V. Soler Chrysler-Plymouth, Inc., 105 S. Ct. 3346 (1985)., William L. Blagg
Georgia Journal of International & Comparative Law
No abstract provided.
The Joint Venture And Related Contract Laws Of Mainland China And Taiwan: A Comparative Analysis,
2015
University of Kansas
The Joint Venture And Related Contract Laws Of Mainland China And Taiwan: A Comparative Analysis, Clyde D. Stoltenberg, David W. Mcclure
Georgia Journal of International & Comparative Law
No abstract provided.
Defining A Country's "Fair Share" Of Taxes,
2015
Washington University School of Law
Defining A Country's "Fair Share" Of Taxes, Adam H. Rosenzweig
Florida State University Law Review
The international tax regime is facing a defining moment. As stories of multinational companies expatriating and shifting income around the world with seeming impunity continue to emerge, the question of how to divide the international tax base among the countries of the world increasingly draws attention from policy-makers and academics. To date, however, the debate has tended to devolve into one over the two traditional tools used to divide worldwide tax base—transfer pricing and formulary apportionment. This Article demonstrates that such focus is misplaced on the instruments of dividing the worldwide tax base rather than on first principles. Instead, this …
Net Operating Losses And Mistakes In Closed Tax Years,
2015
James R. Gadwood is a tax associate at Sullivan & Cromwell LLP
Net Operating Losses And Mistakes In Closed Tax Years, James R. Gadwood
NYLS Law Review
No abstract provided.
Who Invented The Single Tax Principle?: An Essay On The History Of Us Treaty Policy,
2015
University of Michigan Law School
Who Invented The Single Tax Principle?: An Essay On The History Of Us Treaty Policy, Reuven S. Avi-Yonah
Articles
In 1997, I wrote an article on the international tax challenges posed by the then-nascent electronic commerce, in which I suggested that the international tax regime is based on two principles: the benefits principle and the single tax principle. The benefits principle states that active (business) income should be taxed primarily by the country of source, and passive (investment) income should be taxed primarily by the country of residence. This is the famous compromise reached by the four economists at the foundation of the regime in 1923 and is not particularly controversial. It is embodied in every one of the …
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises,
2014
Cornell Law School
The Future Of Source-Based Taxation Of The Income Of Multinational Enterprises, Robert Green
Robert A. Green
No abstract provided.
The Interaction Of Tax And Non-Tax Treaties,
2014
Cornell Law School
The Interaction Of Tax And Non-Tax Treaties, Robert A. Green
Robert A. Green
This background note consists of two parts. Part one provides an overview of the extent to which tax matters are currently covered in non-tax treaties. This discussion focuses on the general agreement on tariffs and trade (GATT)/World Trade Organization (WTO) agreement and the North American free trade agreement (NAFTA) (which cover direct tax measures only to a limited extent) and the European Community (EC) treaty (which covers direct tax measures more broadly). Part two outlines the issues raised when tax matters are covered in non-tax treaties.
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment,
2014
Cornell Law School
The Troubled Rule Of Nondiscrimination In Taxing Foreign Direct Investment, Robert A. Green
Robert A. Green
[Abstract needed]
